Case Summary (G.R. No. L-48735)
Nature of the Case and Background
Rodolfo Andaya initially entered a conditional plea of guilty during the earlier proceedings but later, with the advice of counsel, opted for a full and unqualified plea of guilty after receiving clear warnings about the potential consequences, namely the imposition of the death penalty due to aggravating circumstances, including quasi-recidivism. The prosecution presented multiple witnesses, including Judge Sabas Sayon and several police officers, who testified about the events leading up to the murder, affirming Andaya's involvement and confessions.
Evidence and Testimonies
The prosecution’s case rested on several key testimonies detailing the background and circumstances of the crime. Judge Sayon testified about Andaya's affidavits, where he confessed to stabbing Malbas. Other witnesses, including Sgt. Felix Luego and Deputy Chief of Police Bernabe Dujali, corroborated Andaya's confessions, emphasizing his voluntary admission of guilt during the investigation. Testimonies indicated that the murder occurred after an invitation from Andaya's co-accused to participate in a plan to rob Malbas, which ultimately resulted in his death.
Defense's Argument
Andaya's defense sought to classify his actions under Article 297 of the Revised Penal Code, arguing that the murder should be considered as "attempted robbery with homicide," thereby qualifying for a lesser penalty of reclusion perpetua instead of death. The defense pointed to Andaya’s statements during trial that indicated the crime was initiated for robbery. However, they failed to establish that the intent to rob was present at the moment of the killing, as evidenced by subsequent admissions made by Andaya indicating personal motivations for the act.
Prosecution's Rebuttal and Court Rationale
The Solicitor General argued against the defense's position, asserting that the killing was not tied to any theft as no robbery occurred in conjunction with the murder. The Court noted that Andaya himself admitted to killing Malbas for personal revenge rather than for robbery, thus negating the applicability of the lesser charge. The Court then affirmed that the crime perpetrated reached the level of murder, being aggravated by the accused's status as a quasi-recidivist.
Concl
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Case Overview
- This case involves an automatic review of the death sentence imposed on Rodolfo Andaya by the Court of First Instance of Davao on October 10, 1977.
- The death sentence is a second imposition following the first being set aside by the Supreme Court due to an improvident plea of guilty.
- The current death sentence was based on a plea of guilty entered by Andaya after a proper hearing and consideration of the facts.
Procedural History
- The case was remanded for a proper hearing in accordance with Supreme Court directives after the first guilty plea was invalidated.
- During the re-arraignment on August 3, 1977, Andaya changed his conditional plea to an unqualified plea of guilty despite being warned of the potential consequences, including the inevitable imposition of the death penalty.
Evidence Presented
- The prosecution presented multiple witnesses, including:
- Judge Sabas Sayon: Affidavit of Andaya was sworn before him, confirming Andaya's admission of guilt.
- Sgt. Felix Luego: Testified to Andaya's surrender and identification as the murderer of Paulino Malbas.
- Deputy Chief of Police Bernabe Dujali: Confirmed the investigation and Andaya's confession.
- Andres Perez: